Archive for March 2018

An agency of the central government is serving as administrative cover for an inter-connected group of international donor agencies, multinational corporations, international policy and advocacy groups, Indian industries and Indian non-government organisations, all bent on bringing the next wave of industrialisation to food and its sales.

The FSSAI communication to consumers highlights the look, texture, weight and size of vegetables. Good organic produce however is never uniform and is frequently ‘blemished’, which the FSSAI warns against buying.

This next wave of industrial food is based on existing and new genetic engineering and manipulation technologies, none of which there is adequate regulation for (nor, for some of these technologies, even recognition of). The justification created for claiming these technologies are needed is the shift from ‘hunger’ to the successors of ‘malnutrition’ which are: ‘hidden hunger’ and ‘micronutrient deficiency’. This shift is seen as having the potential to open up a vast and very lucrative new area of the food sector.

Because of the growing (slowly but steadily) tendency of consumers towards organically grown staple food crops and horticulture, and because of the growing opposition to genetically modified seed and food, the food industry in India is following a new strategy through this central government agency. The strategy includes:
1. Defining what ‘safe’ food is and defining what ‘nutrition’ is.
2. Strengthening and deepening the consumer markets for industrially grown and controlled crops from which processed and packaged food products are manufactured.
3. Protecting the businesses of Indian food (and beverage) companies and foreign food MNCs through legislation.
4. Consolidating the ‘back end’ of industrial retail and processed food – which is the interest of the agricultural biotechnology (agbiotech) corporations, the fertiliser and pesticides companies, the farming machinery industry, the food processing machinery industry, the food logistics sector.
5. Facilitating the further integration in India of the food and pharmaceutical industries through the promotion of food ‘fortification’ and food ‘supplements’.

Buy milk pasteurised, buy it packaged and buy it sealed says FSSAI. Milk is considered by the FSSAI’s international collaborators and local ‘nutrition coalitions’ to be the ideal medium for food ‘fortification’. Using what material? There are no answers.

The agency that has taken the responsibility for seeing this strategy through is the Food Safety and Standards Authority of India (FSSAI). It was established under the Food Safety and Standards Act, 2006 (No.34 of 2006). The FSSAI is described as having been “created for laying down science based standards for articles of food and to regulate their manufacture, storage, distribution, sale and import to ensure availability of safe and wholesome food for human consumption”.

The 2006 Act subsumed central acts like the Prevention of Food Adulteration Act 1954, Fruit Products Order 1955, and the Meat Food Products Order 1973. Other legislations like the Vegetable Oil Products (Control) Order 1947, Edible Oils Packaging (Regulation) Order 1988, Solvent Extracted Oil, De-Oiled Meal and Edible Flour (Control) Order 1967, Milk and Milk Products Order 1992 were repealed when the Food Safety and Standards Act 2006 commenced.

It is during the last two years in particular that the FSSAI has become very much more visible and active. This heightened visibility is a result of the FSSAI using the powers it has directly through the 2006 Act, but also because of its widening alliances with the food and beverages industry, with the dairy and milk products industry and with the global ‘nutrition’ consortia.

Edible oils must be packaged says FSSAI. The oil ‘ghani’ is scarcely seen nowadays, but its produce was fresher and gave households more confidence about the purity of the produce than blended oils can. Edible oils from GM oilseeds or GM vegetable oil sources are being imported with no safety oversight whatsoever, but FSSAI’s insistence that packaged edible oil is ‘safe’ discriminates against oil pressed at small scale from local oilseeds that may be entirely organic.

Today the FSSAI is very close to becoming a single reference point for all matters relating to food safety and standards, and is also very close to becoming the most important arbiter of what is considered ‘nutrition’ and what is considered ‘safe food’ in India. Because of the growth in recent years of the processed and packaged food industry (not the same as agriculture, horticulture, collection of forest products, inland and coastal small fisheries) the importance of a single reference point agency increases even more.

The largest formal industry associations – CII, Assocham and FICCI – estimate that in 2017 the retail or store value of packaged and processed foods (and beverages) was about 2,048,000 crore rupees (about US$ 320 billion) in 2016. This enormous estimate is thought by the industry to be able to rise much more to around 3,400,000 crore rupees (about US$ 540 billion) by 2021-22 provided of course changes are made in regulation, called ‘ease of doing business’ (the calamitous benchmark of the World Bank). The FSSAI is to be seen as a critical part of the overall apparatus to reach this gigantic sum in the next five or six years.

It is entirely possible if the FSSAI and its accomplice government agencies and ministries are permitted by us to get away with it. The same industry associations (interest clubs of companies and investors) say that the FMCG (fast moving consumer goods) sector in India has grown in rupee terms at an average of about 11% a year for the last decade and that four out of every 10 rupees spent on FMCGs are spent on food and beverages.

With practically no remaining restrictions on foreign direct investment (FDI) in the food and retail sector, and with the former Foreign Investment Promotion Board (under the Department of Economic Affairs, Ministry of Finance) being replaced as an ‘ease of doing business’ change with the Foreign Investment Facilitation Portal (under the Department of Industrial Policy and Promotion, Ministry of Commerce and Industry) the central government has done its bit to level – dangerously for both consumer health and for environmental well-being – the playing field.

For cereals and pulses too the FSSAI wants consumers to buy packaged, uniformly sized and fortified produce. The don’ts are fair but the dos only fulfil the agbiotech-pharma agenda.

The web of inter-connections that together exert great power over the food industry – and because of it over agriculture, horticulture, forestry products and fisheries – can be seen in how the FSSAI is set up and which agencies it advises. Its administrative ministry is the Ministry of Health and Family Welfare. The FSSAI works closely with the Ministry of Women and Child Development (its object being the Integrated Child Development Services, ICDS, which provides food, pre-school education, and primary healthcare to children under 6 years of age and their mothers), with the Department of School Education and Literacy of the Ministry of Human Resource Development (its object being the Mid-Day Meal Scheme).

The FSSAI relies on the Department of Industrial Policy and Promotion (Ministry of Commerce and Industry) to bring in (through the FDI route) or encourage private sector units that will prepare and deliver the material for food ‘fortification’ and food ‘supplements’. It coordinates with the Department of Animal Husbandry, Dairying and Fisheries (Ministry of Agriculture) concerning the dairy industry – working directly with the National Dairy Development Board to ‘fortify’ milk. It synchronises its rules and regulations with the Ministry of Food Processing Industries, which is the single point of reference for an industry that has become gigantic.

Frozen foods are energy sinks and are the very antithesis of healthy meal ingredients. But FSSAI has a place for them in its advice to consumers.

Furthermore the FSSAI works in tandem with the Department of Biotechnology (Ministry of Science and Technology) and the Department of Health Research (Ministry of Health and Family Welfare) in a joint effort to bring in and to develop biotechnology, genetic engineering and gene modification, and to find ways to publicise justifications (contrary to the great mass of scientific study that show GMOs to be harmful to humans, animals, soil and insects) for the use of these technologies and methods.

Thus although the FSSAI is considered by the Union Government of India to be an agency that has replaced multi-level, multi-departmental areas of control to a single line of command, just like the Foreign Investment Facilitation Portal or the Cabinet Committee on Economic Affairs, these are agencies which do their work in concert, and that concert is played to the tune of the global agbiotech industry, the global food retailers, the e-commerce merchants and all their Indian corporate partners, subsidiaries and otherwise serfs.

Where genetically modified seed and crop, genetic engineering and gene manipulation in food ingredients and therefore food products are concerned, the FSSAI adopts the principle of lying low and saying nothing. In this its behaviour is consistent with that of the Genetic Engineering Appraisal Committee (GEAC, under the Ministry of Environment, Forest and Climate Change, but over which the Department of Biotechnology has controlling influence) and the Indian Council of Medical Research (responsible for the formulation, coordination and promotion of biomedical research and which is administered by the Department of Health Research, Ministry of Health and Family Welfare), both of which lie lower and say even less.

Even condiments and spices are passed by FSSAI as good to consume provided they are packed, packaged and sealed. In this way, the agency is preparing the ground for outlawing non-packaged, freshly ground and prepared foods and spices.

There can be no excuse of any kind for these imports having taken place (and these are only the ones we have learnt about – seeds for planting can be imported via airfrieght at any international air cargo terminal in India). Till today, the Department of Consumer Affairs (Ministry of Consumer Affairs, Food and Public Distribution) has a well-publicised programme and campaign of consumer awareness – on such matters as maximum retail price, expiry date of food products, batch number and correct weight – but not on whether a food product has ingredients from GM crop and why it is important for a consumer to know this.

This is deliberately withholding information from consumers about food and food products that government agencies are certifying and permitting to be sold. While for organic foods there is a new regulation requiring quality assurance and traceability – under the Food Safety and Standards (Organic Foods) Regulations, 2017 – which attest to a product’s ‘organic status’ and its ‘organic integrity’, there is none whatsoever for products that have a GM ingredient.

“Essential nutrients”, “daily requirement”, “fight infections”, “strong and healthy”. The FSSAI uses the marketing gibberish of the infant and baby foods industry to daze consumers into believing that food ‘fortification’ is essential.

But not a word about GMOs, over which we have had scarcely any regulation, and none at all about synthetic biology (also known as GMOs 2.0), which are not even close to being recognised as needing immediate regulation in India. Both generations of GMO survive by inventing and exaggerating claims of experimental science whose human, toxicological and environmental safety has not been studied thoroughly, by an absence of labelling to stringencies that are demanded of organic produce, by putting industry in control of food systems, by threatening biodiversity.

Some examples from elsewhere in the world are ‘probiotic yoghurt’ made out of engineered bacteria and other microorganisms which are intended to change bacteria inhabiting the human digestive tract, ‘gene sprays’ that can be sprayed directly onto crops in the feld to manipulate the genetics of pests and the terrible ‘gene drives’ which permanently ‘drive’ a genetic trait through a species to change the entire population forever by making it dependent on chemicals or to go extinct.

Warnings about allergies and additives. Why not about GM ingredients?

The FSSAI and its host ministry, the GEAC and its host ministry, every administrative apparatus of the Union Government and of the state governments are silent on this matter. They are just as silent on the question: of what materials are these so-called ‘fortification’ made?

The international donor agencies working with the FSSAI and being consulted by the agency on ‘safe food’, ‘nutrition’ and food fortification are the Bill and Melinda Gates Foundation, the Clinton Health Access Initiative, the Coalition for Food and Nutrition Security, the Food Fortification Initiative, the Global Alliance for Improved Nutrition, the Iodine Global Network, Nutrition International, PATH, the Tata Trusts, UNICEF, the World Food Programme, the World Health Organisation and the World Bank. Each has an agenda that goes far beyond ‘food safety’. One or more of them undoubtedly has the answer.

All the conditions that are pointed to (wasting, stunting, chronic under-nutrition, anaemia) as needing remedies from food ‘fortification’ and ‘supplements’ can be easily remedied through more sensible crop cultivation choices and diets that are agro-ecologically and culturally sound. But food has long been a means of control, and this is the work that FSSAI does beyond and behind the ‘safety’ and ‘standards’ part of its mandate.